PRACTICE AREA
International Trust & Estate Planning
Cross-Border Wealth Structuring, Foreign Trusts, and Multi-Generational Planning for International Families
High-net-worth individuals and families with connections to multiple countries face unique challenges in structuring their wealth for both tax efficiency and generational transfer. Foreign trusts, offshore entities, civil law structures such as usufructs, and internationally mobile beneficiaries all create layers of U.S. tax complexity. The distinction between foreign grantor and foreign nongrantor trusts — which determines who is taxed on trust income, how distributions are treated, and whether the throwback rules apply — is central to any cross-border planning engagement.
Our Services Include:
Foreign grantor trust planning — maintaining grantor trust status and the tax benefits it provides for non-U.S. grantors
Analysis of foreign nongrantor trusts — DNI, UNI, throwback tax, and interest charge rules for U.S. beneficiaries
Form 3520 and Form 3520-A reporting compliance for U.S. persons with foreign trust connections
Planning for distributions from foreign trusts to U.S. beneficiaries
Cross-border life insurance and ILIT structuring — addressing estate tax liquidity for NRA clients with U.S.-situs assets
U.S. gift and estate tax planning for non-resident aliens and mixed-domicile couples
Usufruct analysis under U.S. estate and gift tax rules — IRC §2036 retained interest issues and coordination with French and Spanish civil law planning
Generation-skipping transfer (GST) tax planning in the cross-border context
Multi-jurisdictional estate plans coordinated with foreign counsel